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ARTICLE · 23 SEPTEMBER 2025

EPA Proposes Sweeping Rollback Of Greenhouse Gas Reporting Program

Holland & Hart LLP
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On September 12, 2025, EPA announced a proposal to effectively rescind the Greenhouse Gas Reporting Program (GHGRP), which EPA promulgated 15 years ago under its general Clean Air Act (CAA) authority.

United StatesEnvironment
Emily Schilling
Emily Schilling
Ryder Seamons
Ryder Seamons

On September 12, 2025, EPA announced a proposal to effectively rescind the Greenhouse Gas Reporting Program (GHGRP), which EPA promulgated 15 years ago under its general Clean Air Act (CAA) authority. This federal program required 47 categories of large greenhouse gas emitters, fuel and industrial gas suppliers, and CO2 injection sites to measure and report their annual emissions. Under EPA's new proposal, reporting obligations for 46 of the 47 covered source categories would be eliminated entirely, with 2024 as the final reporting year.

The GHGRP historically required annual emissions reporting from major industrial sources as well as manufacturers and production facilities whose annual emissions exceed 25,000 tons of CO2 per year. Today, EPA receives data from more than 8,000 direct emitters and greenhouse gas suppliers spanning a wide range of industries. This information has been the gold standard of emissions reporting and is used in emissions inventories,

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